The American Industrial Hygiene Association® (AIHA) participated in a public hearing hosted by OSHA on March 5 to discuss modifications to the Hazard Communication Standard to Conform to the United Nations’ Globally Harmonized System of classification and Labeling of Chemicals (GHS), according to an AIHA press release. In anticipation, AIHA prepared comments to the proposed revisions and submitted its “Proposal to Modify the Hazard Communication Standard to Conform to the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS)” at the hearing.

“AIHA shares the concerns that inaccurate, incomplete, and outdated Material Safety Data Sheets (MSDSs) can increase risks of illnesses and injuries and environmental consequences arising from the handling, storage, transportation, and use of hazardous chemicals. Industrial hygiene, safety, emergency response, and environmental health professionals rely on MSDSs as a source of information to assist employers and employees properly manage hazardous chemicals,” says AIHA President Cathy Cole, CIH, CSP.

In the proposal comments, AIHA discussed parts of the OSHA proposal that it supports and gave recommendations regarding areas of concern. Cole further states, “AIHA agrees the proposed modifications to the Hazard Communication Standard (HCS) will improve the quality and consistency of hazard communication information provided to employers and employees.”

One of the recommendations that AIHA makes is on the proposed requirement that OSHA permissible exposure limits (PELs), as well as other exposure limit used or recommended by the chemical manufacturer, importer are included on the Safety Data Sheet. AIHA believes that if OSHA allows the inclusion of other occupational exposure limits used or recommended by chemical manufacturers, importers, or employers, then the agency must take this a step further and add a non-mandatory appendix to the HCS to incorporate reference to the TLVs and other occupational exposure limits like the Workplace Environmental Exposure Levels (WEELs).

AIHA cited several explanations as to why the requirement should be extended to include these additional occupational exposure limits. The association also requests that OSHA work with stakeholders to address the issue of updating PELs. In its conclusion, AIHA highlights parts of OSHA’s proposal that it supports, including the proposed implementation schedule in the proposal.

“The GHS, when fully implemented, will facilitate international trade in chemicals and provide a recognized framework that adds to the protection of employers and employees. AIHA pledges our full assistance to OSHA, other regulatory bodies, industry, and the international community to see that the GHS accomplishes its intended objectives. AIHA’s concern continues to be the prevention of health risks to workers and others,” says Cole.

AIHA’s full comments are available for review at